EXPORT 

PROMOTION

Trade Agencies 

Should Enhance 

Collaboration with 

State and Local 

Partners

Report to the Chairman, Committee on 

Small Business, House of 

Representatives

May 2014

GAO-14-393

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-393, a report to the 

Chairman, Committee on Small Business, 

House of Representatives

May 2014

EXPORT PROMOTION

Trade Agencies Should Enhance Collaboration with 

State and Local Partners

Why GAO Did This Study

The 2010 National Export Initiative 

calls for the federal government to 

coordinate more with state and local 

governments and other public and

private partners on export promotion.

Recently, the TPCC identified three 

key initiatives to enhance collaboration

among federal, state, and other

partners. Congress requested that 

GAO review federal and state 

collaboration in export promotion.

This report examines (1) the main 

characteristics of federal and state 

export promotion efforts, including their

collaboration, and (2) the extent to 

which the TPCC has advanced

collaboration between state and 

federal efforts. GAO analyzed federal

and state documents and data from 

2012 and 2013; interviewed officials 

from federal, state, and other export 

promotion organizations; and visited

federal and state trade offices and 

other relevant organizations in five 

states selected as a nongeneralizable 

sample based on their participation in 

the TPCC initiatives and other factors.

What GAO Recommends

GAO recommends that the TPCC take 

steps consistent with key practices for 

collaboration to (1) improve 

implementation of the Export Outreach 

Teams to better achieve their intended

objectives; (2) enhance TPCC 

agencies’ collaboration on export 

promotion with nonfederal entities; and

(3) enhance federal information 

sharing with state trade offices, where

possible, on Commerce’s export 

promotion activities, for example, by 

providing formal guidance to staff on 

allowable information sharing.

Commerce and SBA agreed with 

GAO’s recommendations.

What GAO Found

Federal and state governments share a common interest in promoting exports as 

a tool for economic growth and creating jobs. Both provide similar and 

overlapping export promotion services to similar clients, but their staffing, 

budgetary resources, and ways of measuring performance vary. Located across 

the country, Department of Commerce (Commerce), Small Business 

Administration (SBA), and state trade offices provide outreach, counseling and 

training, and trade leads, mostly to small businesses. In some states, state trade 

offices have more domestic staff than Commerce offices do. However, 

Commerce provides more overall coverage abroad, with offices in 72 countries, 

15 of which have no state trade office representation. In the five states GAO 

visited, federal and state collaboration on export promotion varied from working 

closely in the same location to not collaborating at all, depending on unique 

factors in each state. 

The federal interagency Trade Promotion Coordinating Committee (TPCC) has 

three initiatives designed to advance federal-state collaboration in promoting U.S. 

exports by strengthening and expanding networks of state and local governments 

and other partners. Results of these efforts have been limited, however, in part 

because their implementation has not consistently followed key collaboration 

practices. In prior work, GAO found that collaboration is generally enhanced by

following key practices, such as articulating common outcomes; agreeing on 

roles and responsibilities; monitoring, evaluating, and reporting on results; and 

coordinating resource planning. In the states it visited, GAO found weaknesses in 

the implementation of Export Outreach Teams, a TPCC initiative. For example, in 

some cases, activities were missing key participants and were inconsistent with

the activities’ objectives, in part because SBA is not fully monitoring 

implementation of the teams across its 68 district offices. Similarly, GAO found 

that TPCC’s involvement in a Brookings Institution initiative to engage

metropolitan areas in export promotion has unknown implications for federal 

export promotion efforts and resources because Commerce lacks a means to 

monitor the initiative’s results. Finally, an agreement between Commerce (the 

TPCC Chair) and a national group representing state trade offices expired 

without achieving its collaboration objective or enhancing client information 

sharing so states can share credit with Commerce for helping companies make 

export sales. According to Commerce, by law, it cannot release its clients’ 

confidential commercial information, and its policy is to make determinations on 

releasing information case by case, but it does not provide formal guidance to 

staff on what information sharing is allowable.

TPCC Initiatives to Promote Federal-State Collaboration in Export Promotion

View GAO-14-393. For more information, 

contact Kimberly Gianopoulos at (202) 512-

8612 or gianopoulosk@gao.gov.
Page i GAO-14-393 Export Promotion

Letter 1

Background 4

Federal and State Export Promotion Efforts Have Key Similarities 

but Vary in Staffing and Budgetary Resources, Performance 

Metrics, and Extent of Collaboration 6

TPCC Initiatives to Promote Federal-State Collaboration Have 

Had Limited Results, Due in Part to Inconsistent Use of Key 

Practices 20

Conclusions 36

Recommendations for Executive Action 36

Agency Comments 37

Appendix I Objectives, Scope, and Methodology 40

Appendix II Commerce and State Trade Office Representation Overseas 45

Appendix III Comments from the Department of Commerce 48

Appendix IV GAO Contact and Staff Acknowledgments 50

Table

Table 1: Export Promotion Services Provided by the Department 

of Commerce’s (Commerce) Commercial Service, Small 

Business Administration (SBA), and State Trade Offices in 

the Five States GAO Visited 8

Figures

Figure 1: Total Dollar Value of Annual U.S. Exports, 2009 to 2013, 

and Export Level Needed to Meet 2014 National Export 

Initiative Goal 8

Figure 2: Overview of Commerce and State Trade Office 

Presence in Selected States 12

Contents
Page ii GAO-14-393 Export Promotion

Figure 3: Top 10 Countries in Which State Trade Offices Had 

Representation as of February 2014 14

Figure 4: Dollar Value of Commercial Service Export Successes 

by State Groupings, in Fiscal Year 2012 16

Figure 5: Expected Outcomes, Suggested Membership, and 

Planned Activities of Export Outreach Teams 24

Figure 6: Metropolitan Export Initiative/Global Cities Exchange 28

Figure 7: Commerce and State Trade Office Representation 

Overseas 46

Abbreviations

Commerce Department of Commerce

CS Commercial Service

CTS Client Tracking System

GPRA Government Performance and Results Act

ITA International Trade Administration 

MOA memorandum of agreement

MOI memorandum of intent

NEI National Export Initiative 

SBA Small Business Administration

SBDC Small Business Development Center

SIDO State International Development Organizations

STEP State Trade Export Promotion 

TPCC Trade Promotion Coordinating Committee

USEAC United States Export Assistance Center

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Page 1 GAO-14-393 Export Promotion

441 G St. N.W.

Washington, DC 20548

May 21, 2014

The Honorable Sam Graves

Chairman

Committee on Small Business

House of Representatives

Dear Mr. Chairman:

Given the importance of U.S. exports in supporting economic growth, in 

2010, the President announced the National Export Initiative (NEI) aimed 

at doubling U.S. exports in the next 5 years.1 The Office of Management 

and Budget (OMB) subsequently identified the NEI’s goal of doubling U.S. 

exports as one of 14 interim crosscutting priority goals under the GPRA 

Modernization Act.2 The NEI identifies increased coordination among the 

federal government and its nonfederal partners as a priority and a tool for 

increasing exports.3

 1

The President launched the National Export Initiative in his January 2010 State of the 

Union Address. Subsequently, in Executive Order 13534 (Mar. 11, 2010), the President 

established a new body, the Export Promotion Cabinet, to develop and coordinate the 

implementation of the NEI. The Export Promotion Cabinet is coordinated by a White 

House official, has most of the same member agencies as the Trade Promotion 

Coordinating Committee (TPCC), and is to coordinate its efforts with the TPCC. For a list 

of TPCC member agencies, see 

Congress called for such coordination more than two 

decades ago in the Export Enhancement Act of 1992, which directed the 

President to establish the interagency Trade Promotion Coordinating 

Committee (TPCC) to coordinate U.S. government export promotion and 

export financing activities and develop a U.S. government-wide strategic 

http://export.gov/advocacy/eg_main_022762.asp.

2

This act calls upon OMB to develop long-term, outcome-oriented goals for a limited 

number of crosscutting policy areas and to provide information on how they will be 

achieved. Parts of the act do not come into effect until the 2015 budget is issued, but the 

act requires OMB to develop interim goals starting with the 2013 budget. Pub. L. No. 111-

352, 124 Stat. 3866 (2011) (amending the Government Performance and Results Act of 

1993, Pub. L. No. 103-62, 107 Stat. 285 (1993)). For comments on each of the interim 

crosscutting priority goals provided in the President’s budget, see GAO, Managing for 

Results: GAO’s Work Related to the Interim Crosscutting Priority Goals under the GPRA 

Modernization Act, GAO-12-620R (Washington, D.C.: May 31, 2012).

3

In September 2010, the Export Promotion Cabinet issued the Report to the President on

the National Export Initiative, which is its plan for doubling U.S. exports in 5 years. All 

further references to the NEI in this report include the Export Promotion Cabinet and its 

activities.
Page 2 GAO-14-393 Export Promotion

plan for carrying out such federal programs.4 The act also called for the 

TPCC, chaired by the Secretary of Commerce, to review efforts by the 

states to promote U.S. exports and propose ways to develop cooperation 

between federal and state efforts.5

In light of the federal government’s emphasis on the importance of 

promoting U.S. exports, you asked that we review federal and state 

collaboration in export promotion, which includes activities undertaken by 

government agencies to assist U.S. businesses with the process of 

bringing goods and services to market in other countries. This report 

examines (1) the main characteristics of federal and state export 

promotion efforts, including their collaboration, and (2) the extent to which 

the TPCC has advanced collaboration between state and federal efforts 

to promote U.S. exports.

To determine the main characteristics of federal and state export 

promotion efforts, including their collaboration, we compared their 

services, types of clients, and performance measures using information 

collected from documents and interviews from the Department of 

Commerce’s (Commerce) Commercial Service (CS), the Small Business 

Administration (SBA), and state trade offices in five states (Florida, 

Minnesota, Oregon, Pennsylvania, and Virginia). We chose these states 

based upon the following criteria: presence of relevant Commerce and 

SBA officials; participation in export promotion initiatives we were 

evaluating; state trade office presence overseas; extent of state-level 

export promotion activities according to Commerce officials in 

Washington, D.C.; and state trade office staff size (mix of large and 

small). We chose these five locations to better understand and test 

federal initiatives to advance collaboration with state trade offices at the 

local level. This allowed us to assess federal implementation efforts 

overall, but these five locations are not representative of the situations in 

each of the individual 50 states.

 4

Pub. L. No. 102-429, § 201, 106 Stat. 2186 (15 U.S.C. § 4727).

5

Id.
Page 3 GAO-14-393 Export Promotion

We also analyzed data collected by the State International Development 

Organizations (SIDO) in its annual member surveys for 2012 and 2013.6

We also determined the extent to which CS and state trade offices share 

operational costs and clients. We gained additional insights into how CS 

and state trade offices work together in providing their services by 

examining 2012 data in Commerce’s Client Tracking System.7

To assess the extent to which TPCC has supported collaboration 

between federal and state efforts to promote U.S. exports, we focused on 

three initiatives identified by TPCC officials. We examined SBA guidelines 

for Export Outreach Teams, and the TPCC Interagency Communiqué 

about the teams; reviewed the memorandum of agreement (MOA) on the 

Metropolitan Export Initiative signed by Commerce and the Brookings 

Institution,8 as well as export plans for four metropolitan areas developed 

in the pilot phase of that initiative; and reviewed the memorandum of 

intent (MOI) signed by Commerce and SIDO, an agreement outlining 

plans to collaborate. We analyzed the information we gathered on the 

three initiatives to assess the extent to which their collaboration efforts 

were consistent with key practices and considerations for interagency 

collaboration identified by previous GAO work.9

 6

To assess the reliability of the survey data from the SIDO, we interviewed the SIDO 

representatives responsible for developing and implementing the survey, performed a 

formal review of the survey questionnaire for methodological quality, and performed data 

testing. We determined that some of the survey data were reliable for the purposes of this 

report. 

We also interviewed

officials from state trade offices; SBA District Offices; and U.S. Export 

Assistance Centers (USEAC) in Florida, Minnesota, Oregon, 

7

On the basis of interviews with knowledgeable agency officials and our assessment of 

the data for missing data, outliers, and obvious errors, we concluded that all data 

elements we assessed in the export successes data provided to us by Commerce were 

sufficiently reliable for the purposes of this report.

8

The Brookings Institution is nonprofit public policy organization based in Washington, 

D.C.

9

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 

We identified these practices through interviews with experts on collaboration and a 

review of findings from a number of our previous reports on collaboration in the federal 

government; and Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012). To develop 

these considerations, we reviewed relevant literature, including our prior work, and 

interviewed experts in the area of collaboration.
Page 4 GAO-14-393 Export Promotion

Pennsylvania, and Virginia. Where recommended in those states, we 

interviewed other entities including trade associations, economic 

development organizations, and Small Business Development Centers 

(SBDCs). In addition, we interviewed officials from the mayors’ offices in 

Miami, Florida; Minneapolis, Minnesota; and Portland, Oregon. In 

Washington, D.C., we interviewed officials from the TPCC, Commerce’s 

International Trade Administration (ITA), as well as from SIDO, the 

National Governors Association, and the Brookings Institution. We took 

into account past GAO work on export promotion and related 

performance audits by the Commerce Office of Inspector General. We 

also reviewed the TPCC authorizing legislation, current and past National 

Export Strategies, and the President’s NEI. See appendix I for further 

details of our objectives, scope, and methodology.

We conducted this performance audit from February 2013 to May 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Export promotion activities include efforts to raise awareness about 

exporting and to provide businesses with export counseling, training, and 

information on market opportunities; help connecting with potential buyers 

abroad; and help obtaining financing. Responsibility for export promotion 

is widely dispersed. Many federal and state agencies operate a wide 

variety of programs across the country and overseas that are intended, at 

least in part, to assist U.S. companies in entering foreign markets, or in 

expanding their existing presence in markets abroad.

Some of the 20 TPCC member agencies directly assist small 

businesses10

 10Throughout this report, we use the term “small businesses” in keeping with SBA’s 

definition of a small business as an enterprise that is independently owned and operated, 

organized for profit, and not dominant in its field. SBA’s definition of a small business also 

sets industry-specific standards for other factors, including maximum number of 

employees and annual revenue, to identify how large a company may be and still qualify 

for SBA assistance. 

to export overseas, including Commerce, SBA, the ExportBackground
Page 5 GAO-14-393 Export Promotion

Import Bank, the Departments of State and Agriculture, and the U.S. 

Trade Development Agency. This review of export promotion efforts 

focuses solely on Commerce and SBA because their activities in this area 

are similar to those of state governments.

The TPCC Secretariat is housed in Commerce’s ITA and takes the lead in 

coordinating the activities of federal export promotion activities and 

implementing the NEI through an annual National Export Strategy. The 

ITA also manages CS as part of its Global Markets unit. In most states, 

CS is the primary government entity providing federal export promotion 

services to non-agricultural businesses. Commerce’s mission includes 

strengthening the international economic position of the United States by 

facilitating global trade and opening up new markets for U.S. goods and 

services. CS’s network of domestic and international trade professionals 

seeks to increase exports of goods and services from the United States.11

SBA’s key roles in export promotion are to conduct outreach and provide 

training, counseling, and export financing for small businesses. Within 

SBA, the Office of International Trade has primary responsibility for export 

promotion efforts. The Office of International Trade field staff are mainly 

responsible for providing outreach, training, and technical assistance on 

SBA’s export finance programs. In addition, one person in each of SBA’s 

68 District Offices is designated as a District International Trade Officer 

and provides basic export assistance as a collateral duty. The District 

International Trade Officers are managed by a separate SBA office, 

SBA’s Office of Field Operations. SBA partially funds SBDCs, which are 

located primarily at colleges and universities as a cooperative effort 

among SBA, the academic community, the private sector, and state and 

local governments. Our January 2013 report on the SBA’s role in export 

promotion noted that in addition to providing general business services, 

SBDCs may help businesses interested in exporting, particularly those 

that are new to exporting and need assistance with preparing their 

business to export.

While CS’s mission identifies small businesses as a particular focus of its 

export promotion efforts, CS assists companies of all sizes.

12

 11See 15 U.S.C. § 4721.

The report also noted that while most SBDCs 

12See GAO, Export Promotion: Small Business Administration Needs to Improve 

Collaboration to Implement Its Expanded Role, GAO-13-217 (Washington, D.C.: Jan. 30, 

2013). SBA concurred with our recommendations.
Page 6 GAO-14-393 Export Promotion

provide export assistance as one of many business-development 

services, some SBDCs meet SBA’s criteria to be designated as 

International Trade Centers that focus primarily on providing export 

assistance to businesses.

Every state government conducts some export promotion activities. Statelevel trade functions can be housed in various state government entities, 

including governors’ offices, state departments of commerce, and state 

departments of economic development.13 State trade offices often have 

both domestic and international staff; while domestic staff generally are 

state employees, international staff may work directly for the state trade 

office or may work as contractors.

The federal government and state trade offices across the country work to 

promote exports, offering similar services to similar types of clients, 

primarily small businesses. When government agencies and state trade 

offices have similar goals, activities, strategies, or beneficiaries, their 

programs may overlap. This overlap may be beneficial for clients if federal 

and state offices collaborate to better address the demand for export 

promotion services. However, gaps in collaboration may result in an 

inefficient use of limited resources dedicated to export promotion. We 

found that although federal agencies and state trade offices overlap to 

varying degrees in their provision of export promotion services, their 

staffing levels, resource levels, and metrics for measuring program 

effectiveness often differ. Furthermore, we found that although increased 

collaboration may increase the efficiency and effectiveness of overlapping 

export promotion efforts, the extent of collaboration between federal 

agencies and individual state trade offices varies widely.

 13In this report, we refer to all state government entities providing export promotion as 

“state trade offices.”

Federal and State 

Export Promotion 

Efforts Have Key 

Similarities but Vary in 

Staffing and 

Budgetary 

Resources, 

Performance Metrics, 

and Extent of 

Collaboration
Page 7 GAO-14-393 Export Promotion

In seeking to promote exports, the federal government and state trade 

offices provide services that overlap to varying degrees. By definition, 

overlap occurs when programs have similar goals, engage in similar 

activities or strategies to achieve them, or target similar beneficiaries.14

Officials at both U.S. Export Assistance Centers (USEAC)15 and state 

trade offices that we visited told us that they are operating at capacity in 

terms of resources to meet the demand for their export promotion 

services. Consequently, officials at two USEACs and two state trade 

offices that we visited viewed the provision of similar services by different 

organizations as positive for beneficiaries of these services because the 

overlap meant that more resources were available to companies looking 

for help exporting. As we previously concluded, however, without 

enhanced collaboration, overlap may have a negative effect in that limited 

resources may not be used in the most effective and efficient manner.16

Federal and state efforts to provide export promotion services share the 

same goal: to strengthen the economy and create jobs. The President’s 

National Export Initiative (NEI) articulates this goal in very specific terms, 

aiming to double U.S. exports (based on 2009 export levels) by the end of 

2014. Export promotion is also a component of many state strategies for 

economic development and job creation. U.S. exports have increased 

substantially since 2009, reaching record levels in 2013; nevertheless, 

they have fallen short of the levels needed to attain the NEI goal. Figure 1 

illustrates progress toward this goal.

Furthermore, small business beneficiaries could be confused about how 

to access available services and unclear about who could best meet their 

needs.

 14GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, and 

Duplication and Achieve Other Financial Benefits, GAO-13-279SP (Washington, D.C.: 

April 2013).

15USEACs are the more than 100 domestic offices where Commerce’s CS operates, 

including where SBA, the Export-Import Bank, and sometimes state trade offices have 

staff colocated with Commerce’s staff. USEACs were established to act as “one-stop 

shops” that would provide coordinated guidance on export promotion services and 

available financing. SBA’s field staff—Export Finance Specialists—are colocated with 

Commerce in 19 USEACs throughout the United States.

16GAO, Entrepreneurial Assistance: Opportunities Exist to Improve Programs’

Collaboration and Performance Management for Financial Assistance Programs, 

GAO-14-335T (Washington, D.C.: Feb. 6, 2014).

Federal and State Trade 

Offices Provide Similar 

Services to Help Small 

Businesses Export
Page 8 GAO-14-393 Export Promotion

Figure 1: Total Dollar Value of Annual U.S. Exports, 2009 to 2013, and Export Level 

Needed to Meet 2014 National Export Initiative Goal

Note: The line labeled in the legend “Annual exports to meet goal” represents the annual export totals 

required to achieve the 2014 goal of doubling exports over 2009 levels, assuming identical year-toyear percentage increases. Under this assumption, starting in 2010, export totals need to increase by

14.9 percent over the previous year’s totals to double by 2014. Actual yearly export totals may vary 

from “Annual exports to meet goal.” The “Actual exports” bars represent the actual annual exports 

from 2009 to 2013.

Commerce and SBA provide some of the same types of export promotion 

services, such as outreach, counseling and training, and trade leads, as 

most states do through their state trade offices. For example, as shown in 

table 1, we found this to be true in the five states we visited.

Table 1: Export Promotion Services Provided by the Department of Commerce’s 

(Commerce) Commercial Service, Small Business Administration (SBA), and State 

Trade Offices in the Five States GAO Visited

Service Commerce SBA FL MN OR PA VA

Outreach X X X X X X X

Counseling and training X X X X X X X

Trade leads X X X X X X

Financing X X

Source: GAO analysis of Department of Commerce and SBA documents and information from state trade offices.
Page 9 GAO-14-393 Export Promotion

In prior work, we established the following definitions for the four types of 

export promotion services shown in table 1:17

• Outreach. Outreach can include any activity in which agencies 

generally increase public awareness about exporting, including 

seeking to inform businesses or other partners about the export 

promotion services offered by the federal government. Both 

Commerce and SBA conduct outreach to businesses. For example, 

outreach includes Commerce staff attending a trade show and 

counseling clients. Similarly, Commerce or SBA staff may conduct 

outreach at seminars and training sessions, where they meet 

businesses to identify potential clients interested in exporting.18

• Counseling and training. Counseling is specific to the needs of each 

business and can cover a variety of topics relating to international 

trade and exporting, such as helping a business identify a target 

export market or discussing logistics for shipping exported goods. For 

example, Commerce organizes trade missions for U.S. firms that want 

to explore and pursue export opportunities by meeting directly with 

potential clients in their markets. Commerce often refers businesses 

new to exporting to the SBDCs for export training. SBA also provides 

counseling and training, primarily through SBDCs.

• Trade leads. Trade leads, also known as matchmaking, refers to the 

process of connecting businesses with overseas buyers. Commerce 

leverages its international network of Commercial Officers to help U.S. 

businesses set up appointments with potential buyers abroad and to 

notify businesses when foreign buyers are looking to import U.S. 

goods, also known as matchmaking. Also, Commerce organizes trade 

missions for U.S. firms that want to explore and pursue export 

opportunities by meeting directly with potential clients in their markets. 

Typically, SBA does not provide trade leads but does hosts or cosponsors events that link businesses to export management 

companies—intermediaries that represent a company’s product 

overseas and reduce some of the risks associated with exports by 

managing the logistics of the process.

• Financing. SBA assists small businesses with export financing 

through its Office of International Trade. Of the states we visited, 

 17GAO-13-217. For a full list of services provided by Commerce, SBA, and other TPCC 

agencies, visit http://export.gov.

18SBA field staff engage in a variety of activities but are primarily responsible for providing 

technical assistance, outreach, and training on SBA’s export finance programs.
Page 10 GAO-14-393 Export Promotion

Florida is the only state that offers export financing; state trade offices 

generally refer interested clients to SBA and the Export-Import Bank 

for export financing help. While Commerce is not involved in export 

financing, its Commercial Officers at USEACs often refer interested 

clients to SBA and the Export-Import Bank.

Like the state trade offices in the five states we visited, most of the 28 

state trade offices that responded to a 2013 SIDO survey also provide 

export promotion outreach, counseling and training, and trade leads. 

While not all states provide all services, the survey results showed that 

state trade offices provide a range of services such as outreach, which 

can include providing marketing materials; counseling and training, which 

can include export counseling and export readiness training; and trade 

leads, which may result from participation in or coordination of trade 

shows.

In our fieldwork, we found that the depth and breadth of services state 

trade offices provide vary depending on the availability of resources such 

as funding, staff, and overseas capacity. For example, the state of 

Florida’s program provides export counseling, educational events, and 

international trade leads, including international trade missions and trade 

shows. Similarly, the Minnesota Trade Office offers organization of trade 

missions, export counseling, training programs on the export process, 

including creating an export plan, mitigating risk, and understanding trade 

regulations. Virginia also offers a number of export promotion services 

including counseling; training; trade missions; an array of services such 

as in-country market research provided by an extensive network of 

international consultants; and a 2-year business acceleration program for 

selected companies whose goal is to increase their export sales.

While Commerce charges fees for certain services, including those that 

provide trade leads, some states provide their services for free, subsidize 

businesses’ participation in trade missions and trade shows, or both. For 

example, the Philadelphia USEAC operated by Commerce provides 

export counseling, market research, and trade events for a fee. However, 

the Pennsylvania state trade office provides those same services, in 

addition to market-entry strategy development and technical support, at 

no cost to businesses; moreover, the state trade office awards some 

grants to businesses to pay for or partially subsidize some export-related 

activities. Because Commerce charges fees, businesses in some states 

sometimes opt to seek the same or similar services from the state trade 

office rather than from Commerce, according to one state trade office 

official. Both Commerce and a state official from one of the states that we 

Overlap of Federal and State 

Services
Page 11 GAO-14-393 Export Promotion

visited noted that perceived quality of service also influences businesses’

decisions in selecting a service provider for export promotion services.

In addition to providing similar services, the federal agencies offering 

export promotion services at the state level—Commerce and SBA—and 

most state trade offices primarily serve small businesses. According to 

Commerce, the majority of its customers are small businesses, although 

firms of any size may request its services. SBA, by law, offers services 

exclusively to small businesses. In 2012, 97 percent of the over 301,000 

identified U.S. exporters that exported were small and medium-sized 

exporters.19 In the 2013 SIDO survey, of the 22 state trade offices that 

responded, most states reported that small businesses were their primary 

clients.20 Four of the five state trade offices that we visited told us they 

work primarily with small businesses, although three said they also serve 

some larger companies.

In most states, federal agencies and state trade offices have different 

levels of domestic staff resources available for providing export-related 

assistance to companies. As of February 2014, there were 265 domestic 

Commerce CS staff in the 108 USEACs located in every state with the 

exception of Delaware and Wyoming.21

 19Based on U.S. Census Bureau 2012 Preliminary Profile of U.S. Exporting Companies

(Dec. 4, 2013).

SBA also has staff in every state 

that provides export services, and partially funds more than 900 SBDCs 

across the country. Most states have trade offices that also provide 

export-related assistance to businesses. One state trade office reported 

20Twenty-eight states responded to the 2013 SIDO survey; however, not all states 

provided a response to all survey questions. 

21According to Commerce officials, Delaware businesses are served by the Philadelphia 

USEAC, and Wyoming businesses are served through the Denver USEAC. Currently, 11 

USEACs are unstaffed. 

Overlap of Federal and State 

Clients

Federal and State Export 

Promotion Efforts Vary in 

Staff and Budgetary 

Resources and in Metrics 

Used to Track Results

Domestic Staffing Levels
Page 12 GAO-14-393 Export Promotion

only 2 staff while another reported having 28 staff dedicated to 

international trade, according to the 2013 SIDO survey.22

Figure 2: Overview of Commerce and State Trade Office Presence in Selected States

As shown in 

figure 2, for the five state trade offices that we visited, staff numbers 

ranged from 5 full-time employees statewide to 30; the state export 

promotion employees in each state outnumbered the Commerce USEAC 

export promotion employees.

Notes: The number of USEAC staff shown in this figure includes only those from the Department of 

Commerce. Department of Commerce USEAC and staff numbers are as of February 2014; state 

trade office figures vary in terms of month but are all for 2013.

 22In this survey, for example, 18 states provided numbers on their full-time equivalent 

(FTE) employees currently employed by their international economic development 

agencies; the numbers reported were to include all domestic personnel and personnel 

abroad, including state employees and contracted representatives. The mean number of 

officials reported was 13, with the middle 90 percent of states reporting in the range of 2.5 

to 28 FTEs. The mean number of FTEs and ranges were similar for the 2012 SIDO data.
Page 13 GAO-14-393 Export Promotion

Commerce has greater representation abroad than state trade offices. 

Commerce has 930 staff in offices in 72 countries abroad.23 In 15 of these 

countries, no state trade office maintains its own representation.24

Nevertheless, many state trade offices have their own international 

representatives that provide services to businesses from those states 

similar to the services offered by Commerce’s Foreign Commercial 

Officers. This representation is provided by either state employees or 

contractors hired as service providers, or both, and they provide these 

services to a country from offices located in-country or on a regional basis 

from offices not located in-country. While 38 state trade offices 

collectively have representation in 83 countries abroad, the number of 

countries in which individual state trade offices have representation 

varies. For example, Pennsylvania operates abroad relatively 

independently from Commerce through its own network of overseas 

contractors located in 22 countries from which the contractors serve 73 

countries. Similarly, Virginia utilizes a combination of its own staff (in 2 

countries), and overseas contractors, which constitutes a network that 

reaches 57 countries. Conversely, Oregon relies almost exclusively on its 

own staff and contractors in 4 countries where it has representation, but it 

relies heavily on Commerce in all the countries where it has no formal 

representation. Figure 3 shows the top 10 countries in terms of state 

trade office representation, with China, Japan, and Mexico having the 

most. See appendix II for more details on Commerce’s and the states’

export promotion representation overseas.

An 

official from one state explained that Commerce’s presence 

internationally is more important for state trade offices than Commerce’s 

domestic offices in serving the needs of small businesses. This was 

because there is less overlap between states and the federal government 

overseas, according to this official, and a number of states do not have a 

presence overseas and rely entirely on Commerce for those services.

 23Commerce overseas staffing levels are as of November 2013.

24We previously found that Commerce could improve its resource allocation planning 

practices to maximize the effectiveness of limited resources and that it could take steps to 

gather more complete information about export successes, one of the main Commerce 

performance metrics. See GAO, National Export Initiative: U.S. and Foreign Commercial 

Service Should Improve Performance and Resource Allocation Management, 

GAO-11-909 (Washington, D.C.: Sept. 29, 2011).

International Representation
Page 14 GAO-14-393 Export Promotion

Figure 3: Top 10 Countries in Which State Trade Offices Had Representation as of 

February 2014

• In fiscal year 2013, Commerce’s ITA dedicated $267.5 million of its 

total budget to export promotion. SBA’s Office of International Trade, 

which provides export financing and promotion services to small 

businesses, had fiscal year 2013 total program costs of approximately 

$9.8 million. Additionally, SBA’s export-related loans amounted to 

approximately $1.2 billion in fiscal year 2013.25 The total amount of 

money spent on federal export promotion is unclear because 

comparable budget information for federal agencies involved in export 

promotion is not readily available, as we found in July 2013.26

 25Congressional Research Service, Small Business Administration Trade and Export 

Promotion Programs, R43155 (Washington, D.C.: Jan. 22, 2014).

26GAO, Export Promotion: Better Information Needed About Federal Resources, 

GAO-13-644 (Washington, D.C.: July 17, 2013).

Budgetary Resources
Page 15 GAO-14-393 Export Promotion

State governments vary greatly in the budgetary resources they provide 

for export promotion. According to the 2013 SIDO survey, among the 14 

state trade offices that responded to this question, office annual budgets 

ranged from $80,000 to $6.2 million, with 90 percent of the 14 states 

having budgets ranging from $420,000 to $1.75 million.27

Organizations define performance metrics to reflect priorities, measure 

achievement, and create incentives for management and staff. Measuring 

performance allows organizations to track the progress they are making 

toward their goals and gives managers crucial information on which to 

base their organizational and management decisions.

The 5 state 

trade offices we visited had budgets for export promotion that ranged 

from $1.9 million to over $5 million annually for fiscal year 2013. In the 

2013 SIDO survey, of the 23 states that responded to this survey 

question, over half reported no significant changes in their overall budgets 

from the previous year.

28 Commerce 

primarily uses “export successes” to measure performance. When any 

Commerce trade-promotion activity successfully assists a U.S. company 

to export a product or service, Commerce staff document an export 

success that is verified by Commerce management.29

 27In this survey, 14 states provided numbers on their state trade promotion budgets, 

including both domestic costs and costs for overseas offices and contractors. The average 

2013 budget reported by these states was about $960,000, with the totals ranging from 

$72,000 to $3.3 million, and with all but three of the 14 states having budgets between 

$200,000 and $1.74 million. The average budget and overall range for the 21 states that 

responded to the budget question on the 2012 SIDO data were similar to those for 2013. 

Note that these data are only illustrative and cannot be generalized to all states as many 

did not respond to this question in the SIDO survey.

The total dollar 

value of Commerce export successes in each state varies greatly, with, 

for example, export successes from Alaska totaling $370,000 in 2012 and 

export successes from Washington exceeding $10 billion for that same 

year (see fig. 4).

28GAO, Entrepreneurial Assistance: Opportunities Exist to Improve Programs’

Collaboration, Data-Tracking, and Performance Management, GAO-13-452T 

(Washington, D.C.: Mar. 20, 2013).

29An export success is defined as a Commerce service, rendered by locally employed 

staff, Foreign Service Officers, or USEAC staff that facilitates (1) a sale of a product or 

service; (2) a commercial agreement (distribution, wholesale, or joint venture); or (3) an 

overseas activity resulting in revenue for a U.S. company or its affiliate or subsidiary.

Metrics Used to Measure 

Performance
Page 16 GAO-14-393 Export Promotion

Figure 4: Dollar Value of Commercial Service Export Successes by State Groupings, in Fiscal Year 2012

Note: Export successes reported for fiscal year 2012 represent those approved in fiscal year 2012, 

which include some export successes that occurred in previous calendar years.
Page 17 GAO-14-393 Export Promotion

State trade offices use a variety of metrics to gauge progress, including 

measures similar to Commerce export successes. According to the 2013 

SIDO survey, the 26 state trade offices that responded to these survey 

questions reported using one or more of the following categories to 

measure export promotion activities:30

• dollar amount of export transactions assisted by the state;

• number of jobs created or retained;

• number of new clients assisted;

• quality of service provided to clients;

• number of deals made;

• number of deals anticipated; and

• total state export value.

States that we visited also used a variety of metrics to measure export 

promotion activities. One trade office tracked export sales that it helped 

generate using a methodology similar to the one used by Commerce to 

track export successes, whereas another state trade office used client 

satisfaction surveys exclusively. This state trade office Director explained 

his office focuses on quality of services because his office has no direct 

influence on whether a given client company actually exports. In contrast, 

another state trade office uses a formula for measuring performance that 

incorporates several variables, such as the number of companies served 

annually, the number of export activities in which a company participates 

(i.e., attending a trade show, meeting with a distributor), and the total 

export sales assisted by the state trade office.

In the five states we visited, we found that the extent of collaboration 

between federal and state trade offices ranged from no collaboration in 

one state, to very little collaboration in another, to close collaboration 

between federal and state export promotion providers in three states.

According to federal and state officials with whom we spoke, factors 

affecting their level of collaboration included physical proximity, level of 

communication, and resource levels. In addition, we note that state 

offices report to their own executive and legislative bodies, and state 

trade offices determine their own priorities and are not obligated to 

 30Some states also reported that they had separate performance measures for overseas 

offices. 

The Extent of Federal and 

State Collaboration Varies 

Widely
Page 18 GAO-14-393 Export Promotion

collaborate with federal agencies.31

Among the five states we visited, we found little to no collaboration with 

federal agencies in two states. One state Director described the state’s 

relationship with Commerce export promotion staff in his state as cordial 

but involving virtually no interaction. In another state, we found minimal 

interaction between the state trade office and the state’s USEACs. In both 

states, local federal officials agreed that they had a limited relationship 

with their state counterparts. Both these state trade offices are wellfunded and provide export assistance services through their networks of 

in-state trade offices and extensive networks of international offices 

staffed by contracted service providers. The Directors of both state trade 

offices noted that in most cases they opt not to work with Commerce 

because their experience has been that Commerce response times are 

slow and that the quality of the service inconsistent. For example, one 

state Director said that his state provides export promotion assistance 

faster, better, and cheaper than Commerce. However, both states 

collaborate with Commerce overseas when their staff or contractors are 

not located in a country or are unable to meet the demand for services 

from exporters. Both states also minimally collaborate with SBA; one 

state refers new-to-export companies to SBDCs for training, while the 

other state refers companies that need export financing to SBA.

States that do choose to collaborate 

with federal partners in trade promotion primarily interact with Commerce 

but also collaborate with SBA, both to varying degrees.

In contrast, we found that staff in three of the five state trade offices we 

visited work closely with Commerce. Officials from these state trade 

offices explained that the services their offices provided complement 

Commerce’s services, and they cited colocation or proximity of offices 

and good communication as factors that facilitate collaboration.32

 31We previously reported that Commerce and the majority of states provide many of the 

same types of export promotion services, but that some states have limited budgets and 

staff. Partly as a result of this limited capacity, most states reported that Commerce’s 

services are important to their export promotion capabilities and have partnered with 

Commerce’s offices. See GAO, Export Promotion: Commerce Needs Better Information to 

Evaluate Its Fee-Based Programs and Customers, GAO-09-144 (Washington, D.C.: Mar. 

4, 2009).

32Fifteen USEACs are colocated (share office space) with a state economic development 

partner, which may include state trade office staff. In an example of proximity, Commerce 

and Business Oregon are located in the same building, which makes collaboration among 

their staff easier because it allows them to be more aware of and more easily build on 

each other’s work.
Page 19 GAO-14-393 Export Promotion

According to Commerce’s client management system,33 for fiscal year 

2012, state trade offices or other state government offices or agencies 

are among Commerce’s most frequent partners in achieving export 

successes.34

• In one state, Commerce and state officials characterized their working 

relationship as seamless and their services and activities as 

complementary. For example, the state organizes trade missions 

while Commerce helps with recruiting companies and arranges oneon-one meetings with prospective buyers. Similarly, officials told us 

that in some cases the state trade office provides funding to 

businesses that is used to purchase Commerce’s services. This state 

trade office and Commerce also occasionally provide joint counseling 

to some companies, according to state trade office officials.

• In another state trade office, located in the same building as

Commerce, the Director believed that a primary factor encouraging 

collaboration was that both offices had small staffs whose members 

knew each other well. According to state trade office officials, this 

state’s trade staff and Commerce’s staff provide joint counseling 

services and promote one another’s services to businesses. This 

state trade office also collaborates with Commerce and SBA to deliver 

export-focused training intended to provide introductory information to 

businesses on the exporting process and available federal resources 

to nonexporting companies.

• A third state trade office described its relationship with Commerce as 

complementary and noted that the organizations collaborate on joint 

trade missions and activities that bring together businesses interested 

in exporting with potential buyers. State trade office officials noted that 

Commerce relies on the state for their export education programs and 

that the state works mostly with new-to-export companies. This state 

trade office refers only companies who require very basic assistance, 

such as basic accounting information, to SBDCs. The Director of the 

state trade office commented that any duplication in the services 

 33Commerce’s client management system for tracking fee-based and non-fee-based 

activities, including interactions with clients, does not require staff to complete the field 

where a partnership on an export success may be reported.

34Also, a 2012 Commerce Inspector General survey reported that state trade offices are 

among Commerce’s most frequent collaboration partners. Other partners included other 

federal agencies and private sector organizations. 
Page 20 GAO-14-393 Export Promotion

provided by Commerce and her office would not be a concern 

because the demand for export assistance in the state was so great.

In two states we visited, SBA grants to state trade offices through the 

State Trade and Export Promotion (STEP) program have facilitated 

collaboration with Commerce and SBA.35 In those states, for instance, 

Commerce refers their clients to state trade offices for STEP funding. The 

state trade offices reported using STEP funds to expand their services or 

replace lost state funding and said they were able to provide for exportrelated activities such as attendance at trade shows and to purchases of 

Commerce services. For example, Minnesota’s Trade Office was using 

STEP funds to provide matching funds to Minnesota businesses for 

export activities and their expenses, including trade missions. As another 

example, in partnering with a local SBDC, Florida’s trade office was using 

STEP funds to help new-to-export businesses create strategic exporting 

plans.

Three TPCC initiatives utilize networks of state and local governments 

and other partners to advance federal-state collaboration in promoting 

U.S. exports. These efforts have produced limited results, however, in 

part because they have not consistently implemented key collaboration 

practices. In prior work, we found that collaboration is enhanced when 

collaborating partners follow certain key practices, such as articulating 

common outcomes; agreeing on roles and responsibilities; monitoring, 

evaluating, and reporting on results; and leveraging resources. In states 

we visited, we found weaknesses in the implementation of Export 

Outreach Teams, a TPCC initiative that was to be co-led by Commerce 

and SBA. Similarly, we found that TPCC’s involvement in a Brookings 

Institution effort to engage metropolitan area economic development 

groups in export promotion has unknown implications for federal export 

promotion efforts and resources. Finally, an agreement between 

Commerce (the TPCC Chair) and a national group representing state 

 35STEP was a 3-year pilot trade and export initiative authorized by Section 1207 of the 

Small Business Jobs Act of 2010 (Pub. Law 111-240, Sept. 27, 2010) and funded at $30 

million per year for the first 2 years. Under the program, SBA made matching-fund grants 

to states to assist “eligible small business concerns” enter and succeed in the international 

marketplace. Services under the program were funded in part by SBA but were provided 

to eligible small business concerns—or “STEP Clients”—by STEP grant recipients located 

in most states and territories and the District of Columbia. During the first 2 years of this 

program, SBA awarded approximately $60 million. 

TPCC Initiatives to 

Promote FederalState Collaboration 

Have Had Limited 

Results, Due in Part 

to Inconsistent Use of 

Key Practices
Page 21 GAO-14-393 Export Promotion

trade offices expired without achieving its collaboration objectives and 

without Commerce addressing ways for it to share within legal restrictions 

more information about its clients with state trade offices.

In prior work, we found that federal agencies face a range of challenges 

and barriers when they attempt to work collaboratively. Such challenges 

and barriers also exist—and sometimes to an even greater degree—

when federal agencies partner with state and local governments, 

nonprofit organizations, and the private sector. However, our prior work 

has also identified practices that can help to enhance and sustain 

collaboration among agencies and thereby maximize performance and 

results, and we have recommended that agencies follow them.36

• Define and articulate a common outcome.

Among 

the key collaboration practices we have identified and recommended in 

prior work are the following:

• Identify and address needs by leveraging resources.

• Develop a mechanism to monitor, evaluate, and report on results.

• Agree on roles and responsibilities.

• We have also found that there are key issues to consider when 

implementing collaborative mechanisms. These include leveraging 

resources, such as human, information technology, physical, and 

financial resources to sustain a collaborative effort, and composing 

written guidance and agreements documenting how the parties to the 

agreement will collaborate and a way to update the guidance and 

agreements as needed.37

The enhanced federal-state collaboration in export promotion envisioned 

in the NEI calls for the implementation of some of these key collaboration 

practices. In its 2010 report to the President on the NEI, the Export 

Promotion Cabinet identified improved coordination with state 

government trade offices as a priority, and called for federal agencies to 

make joint planning the standard procedure in all states that have export 

promotion programs. The Export Promotion Cabinet also stated that 

interagency coordination could be strengthened and that federal-state 

partnership could be particularly helpful in identifying potential exporters 

to meet the NEI goal. In addition, the subsequent National Export 

 36GAO-06-15. 

37GAO-12-1022.

Collaboration Is Enhanced 

When Participants Follow 

Key Practices
Page 22 GAO-14-393 Export Promotion

Strategies highlighted collaboration with state and local governments as a 

priority.38

In support of the NEI, the TPCC’s two most recent National Export 

Strategies made enhancing federal-state collaboration on export 

promotion a priority. The 2011 and 2012 strategies called for increasing 

collaboration with state export promotion programs and metropolitan 

areas. Accordingly, the TPCC identified three initiatives intended to 

increase U.S. exports under the NEI and enhance collaboration between 

federal and state efforts: (1) Export Outreach Teams, created to increase 

local awareness of export promotion resources and facilitate collaboration 

among local networks of export promotion service providers; (2) 

collaboration with the Brookings Institution to support its Global Cities 

Exchange (initially referred to as the Metropolitan Export Initiative), as 

part of TPCC efforts to expand export promotion activities in metropolitan 

areas; and (3) a memorandum of intent (MOI) with a national organization 

that represents state trade offices from across the country, as part of 

TPCC efforts to work with national organizations with common interests. 

The TPCC highlighted the first two initiatives in its 2011 and 2012 

strategies, and TPCC officials told us that the MOI was important to 

federal-state collaboration.

The TPCC promoted Export Outreach Teams as a mechanism for 

bringing together the various organizations that provide export promotion 

services in a locale to share information with small business service 

providers. The Export Promotion Cabinet’s 2010 report to the president 

on NEI and the TPCC’s 2011 and 2012 National Export Strategies 

discuss the role of these teams in leveraging state and local resources to 

help small businesses export successfully. Export Outreach Teams were 

originally a pilot program launched by SBA in 2010 as a way to inform 

small business service providers about local available export resources 

provided by the various federal agencies, state trade offices, and their 

partner organizations. Small business service providers include Small 

Business Development Centers, Women’s Business Centers, SCORE 

 38Furthermore, the Export Enhancement Act of 1992 called for the TPCC to review efforts 

by the states to promote U.S. exports and propose ways to develop cooperation between 

federal and state efforts. A Commerce official noted that federal agencies do not have 

authority over state trade offices and can only encourage their willingness to cooperate.

TPCC Has Identified 

Three Initiatives to 

Enhance Federal-State 

Collaboration

Efforts to Improve Local 

Networks of Export 

Promotion Service 

Providers Have Had 

Limited Results Due to 

Implementation 

Weaknesses
Page 23 GAO-14-393 Export Promotion

offices,39

In 2012, the Export Promotion Cabinet and TPCC issued an interagency 

communiqué that expanded SBA’s Export Outreach Teams across the 

country. In keeping with a key collaboration practice described above, the 

communiqué outlined two main purposes, or common outcomes, for the 

Export Outreach Teams:

local economic development agencies, trade associations, and 

chambers of commerce.

• to increase local small business service providers’ awareness of 

available international trade expertise and

• to enhance communication and collaboration.

According to the interagency communiqué, Export Outreach Teams were 

to serve as a forum for collaboration by including export promotion 

agencies from all levels of government—federal, state, and local. As a 

first step, the communiqué called for team members, including staff from 

Commerce’s CS, SBA, SBDCs, state trade offices, and small business 

service providers to participate in workshops with activities meant to 

advance the program’s objectives. One of those activities was the 

formation of referral protocols that would help to establish roles and 

responsibilities and to leverage available resources. These referral 

protocols were intended to help ensure that local businesses could find 

the right export promotion service provider for their particular needs. The 

interagency communiqué stated that Export Outreach Teams were to 

hold a workshop by September 30, 2013, and that the teams should 

convene quarterly thereafter. Figure 5 shows the expected outcomes, 

suggested membership, and planned activities of Export Outreach 

Teams.

 39SCORE is an SBA-supported nonprofit association that provides assistance to help start 

and expand small businesses though a net work of over 11,000 volunteers nationwide.
Page 24 GAO-14-393 Export Promotion

Figure 5: Expected Outcomes, Suggested Membership, and Planned Activities of 

Export Outreach Teams

a

SCORE is an SBA-supported nonprofit association that provides assistance to help start and expand 

small businesses though a network of over 11,000 volunteers nationwide.
Page 25 GAO-14-393 Export Promotion

The interagency communiqué called for both Commerce and SBA to be 

co-managers of the Export Outreach Teams, but SBA, whose role in 

federal export promotion efforts has grown in recent years,40

Despite TPCC and SBA efforts to provide guidance on achieving the 

objectives of the Export Outreach Teams, we found weaknesses in their 

implementation that limit their ability to enhance federal-state 

collaboration.

took the lead 

in implementing the initiative in its 68 SBA districts across the country. 

SBA provided detailed guidance to each District Office on how to conduct 

the initial team workshops described in the communiqué. SBA tracked the 

dates and numbers of attendees of the initial workshops of the Export 

Outreach Teams through 2013 and reported that all but one district held 

its initial workshop by the September 30, 2013, deadline. In February 

2014, SBA distributed to the District Offices a separate document to track 

the Export Outreach Teams’ quarterly meetings; that document requested 

information from District Offices about the agencies represented, the 

activities planned, and the topics covered at the meetings.

• First, the team memberships and activities were inconsistent with the 

guidance. In some instances, not all relevant participants were 

present at the workshop, while in other instances, the events reported 

as Export Outreach Team workshops did not have the purpose of 

facilitating interagency collaboration. For example, in one location we 

visited, state trade office officials were not aware that the local Export 

Outreach Team existed, and at another site, the Export Outreach 

Team had not included state trade office representatives in its initial 

workshop. According to an SBA document that tracked the attendees 

at the first meetings of all Export Outreach Teams, the participants in 

the meetings varied widely. Teams reported from 4 to 220 attendees 

at their initial workshops, 41

 40

and some meetings reported as Export 

Outreach Team events were larger conferences, presentations to 

small businesses, or other events not intended to serve as a forum for 

interagency and intergovernmental coordination. Officials at two 

locations we visited reported that presentations about SBA’s export 

financing programs were Export Outreach Team workshops, and in 

one location we visited, the Export Outreach Team workshop was in 

GAO-13-217. 

41Some locations did not provide a final tally of all attendees.
Page 26 GAO-14-393 Export Promotion

fact a presentation to private companies, not the intended meeting to 

coordinate local export promotion resources.

• Second, we identified and examined two referral protocols developed 

by Export Outreach Teams and both lacked important details that 

would facilitate the referral process and better communication and 

collaboration. Specifically, the protocols were not consistent with the 

key collaboration practice of agreeing on roles and responsibilities. 

For example, the protocols we examined lacked important details that 

would facilitate the referral process such as information about federal, 

state, and local agency responsibilities and the circumstances under 

which a business would be referred from one agency to another. 

Furthermore, SBA officials did not emphasize the importance of the 

referral protocols, rather stating that they were a desirable but not a 

necessary outcome of the teams. Referral protocols with clear roles 

and responsibilities can help federal and state officials determine 

when to refer businesses to each other, for assistance, and to avoid 

delays and confusion on the part of businesses seeking export 

assistance.

• SBA recently created a document to track the Export Outreach 

Teams’ quarterly meetings and, as of March 2014, plans to use it to 

collect, review, and use the information to manage the program. 

Without monitoring, evaluating, and reporting on results, SBA does 

not know whether the teams are reaching out to and including the 

appropriate organizations, such as state trade offices; whether the 

teams are meeting regularly as intended; and whether the teams are 

exploring ways to foster better collaboration through referral protocols 

or other means. Therefore, SBA has lacked pertinent information 

needed to make decisions in managing the program, including how to 

adjust the program to strengthen local networks of export promotion 

service providers so that businesses receive the best possible 

assistance. As a result, until the TPCC and SBA collect and review 

information on the program, they cannot ascertain the extent to which 

Export Outreach Teams are achieving their objectives to increase 

awareness of local export resources and enhance collaboration 

between federal and state agencies.
Page 27 GAO-14-393 Export Promotion

TPCC officials sought to enhance collaboration among regional, state, 

and local economic development entities to increase their involvement in 

export promotion through a Commerce collaboration with the Brookings 

Institution’s Global Cities Exchange (hereafter referred to as Global 

Cities).42 Initially launched as the Metropolitan Export Initiative, Global 

Cities was established to engage metropolitan area governments and 

other local entities in collaboration with federal and state providers to 

increase exports and economic growth and to broaden global economic 

engagement. The TPCC’s 2011 and 2012 National Export Strategies 

describe this initiative as a tool for federal collaboration with state and 

local governments, and the TPCC has identified it as a mechanism to 

broaden export promotion efforts to include new partners and help reach 

the goal of the NEI. According to the 2012 strategy, collaboration with 

metropolitan areas is particularly important because metropolitan areas 

account for most of the nation’s exports and are home to each region’s 

unique concentration of capital, investment, and innovation. According to 

the Brookings Institution, Global Cities will increase U.S. exports by 

leveraging the knowledge and connections of local economic 

development leaders to proactively identify firms and sectors with the 

greatest export potential, coordinate fragmented export assistance 

providers, and leverage limited resources for maximum benefit. As shown 

in figure 6, federal, state, and metropolitan agencies are to combine their 

varied missions, functions, and perspectives to achieve the Global Cities 

objective of enhancing each metropolitan area’s exports. Other 

participating organizations include universities, chambers of commerce, 

and regional economic development organizations. In 2011, Global Cities 

started in Los Angeles, California; Minneapolis-St. Paul, Minnesota; 

Portland, Oregon; and Syracuse, New York. Another 16 locations started 

the process as of December 2013.43

 42The Global Cities Exchange is a component of the Brookings Institution’s Global Cities 

Initiative. According to a representative of the Brookings Institution, the Global Cities 

Initiative aims to catalyze a shift in economic growth policy that results in more globally 

competitive metropolitan areas by positioning them for high-quality growth and better jobs 

for more workers in the 21st century.

Ultimately, according to the 

43As of December 2013, Global Cities had expanded from the first four locations to also 

include the following cities: Atlanta, Ga.; Charleston, S.C.; Chicago, Ill.; Columbus, Ohio; 

Des Moines, Iowa; Greenville, S.C.; Indianapolis, Ind.; Jacksonville, Fla.; 

Louisville/Lexington, Ky.; Milwaukee, Wisc.; Phoenix, Ariz.; Sacramento, Calif.; San 

Antonio, Tex.; San Diego, Calif.; Tampa, Fla.; and Wichita, Kans. As of April, 2014, the 

Brookings Institution has not announced the remaining eight locations. 

Initiative to Engage 

Metropolitan Entities Has 

Unknown Implications for 

Federal Export Promotion 

Efforts
Page 28 GAO-14-393 Export Promotion

Brookings Institution, Global Cities is to be implemented in a total of 28 

metropolitan areas.

Figure 6: Metropolitan Export Initiative/Global Cities Exchange

Los Angeles, Minneapolis-St. Paul, Portland, and Syracuse have 

completed metropolitan export plans, each of which includes performance 

measures. The export component of Global Cities’ performance 

measures vary by location and include the value of exports as a 

percentage of regional gross domestic product, the increase in the 

number of new-to-export firms, the increase in the number of markets to 

which local companies export, and the number of new firms entering the 

export supply chain. A Brookings Institution representative noted that 

measuring performance across the large and diverse group of 

organizations involved in Global Cities’ efforts is a challenge and that 

Global Cities is hoping to establish coordinated services and develop 

success stories with specific companies.

Commerce has provided resources to support Global Cities in the form of 

staff time and expertise provided at the local level, as specified in the 

memorandum of agreement (MOA) that Commerce signed with the 

Brookings Institution in September 2011. Consistent with key practices for 
Page 29 GAO-14-393 Export Promotion

collaboration, the MOA specified how Commerce would participate in the 

initiative in terms of roles and responsibilities and what resources 

Commerce would devote in four pilot locations.44

The MOA expired in April 2012, and Commerce and the Brookings 

Institution do not plan to renew the agreement. However, Commerce will 

continue to support Global Cities through its USEACs at the local level as 

the program expands to a planned 28 metropolitan areas. A Brookings 

Institution representative stated that the MOA was only intended for the 

initial stage of the program. Similarly, Commerce officials told us they did 

not think it was necessary to renew the agreement with the Brookings 

Institution because they consider their role as limited to advising when 

requested and helping to inform Global Cities’ participants in new 

metropolitan areas about federal export promotion programs and 

services. Furthermore, Commerce officials told us that, because the 

Global Cities projects are implemented locally and facilitated by the 

Brookings Institution nationally, Commerce does not need a process to 

track and report on the results of the initiative in each city.

Subsequently, 

Commerce made several contributions to the program under the MOA, 

including providing data on global demand for U.S. exports in each 

metropolitan area. Furthermore, Commerce staff in each of the four pilot 

cities provided expertise to help develop metropolitan export plans, which 

outline strategies for increasing exports in each location. In some Global 

Cities locations—such as Minneapolis-St. Paul, Minnesota; Portland, 

Oregon; and Tampa Bay, Florida—Commerce officials have participated 

in the planning, development, and implementation of Global Cities

projects, including the development of a document describing local 

export-related resources, providing export-related training to economic 

development professionals, and assisting with a survey of companies to 

understand the perceived challenges they face related to exporting their 

goods and services.

Brookings officials told us that their initiative was meant to increase 

interest in exporting, not to create new export promotion service 

providers. Thus, to the degree the initiative is successful, it will put new 

demands for export promotion services on federal and state export 

 44Under the MOA, Brookings had primary responsibility for implementation—including the 

identification of local leaders for the program and providing data analysis. Brookings also 

provided technical assistance in developing metropolitan export plans and in surveying 

local exporting businesses. 
Page 30 GAO-14-393 Export Promotion

promotion agencies. Of the 20 currently established Global Cities 

locations, 6 are served by a Commerce office of one employee. In 

locations we visited, Commerce officials told us that a lack of staff 

resources was already a concern, which would make it challenging to 

respond to an increase in demand from local businesses for export 

promotion services.

As mentioned previously, metropolitan areas participating in Global Cities 

plan to track their progress through performance metrics specified in their 

metropolitan export plans. However, to date, Commerce has not 

requested these data. Therefore, the impact of the initiative is still 

uncertain. Commerce has no plans to monitor results, which is 

inconsistent with key collaboration practices. With no system in place to 

monitor the results of the Global Cities initiative, Commerce lacks 

information needed to participate effectively because it cannot anticipate 

any increased demand for its export promotion services that the program 

may generate, or know when to shift resources to certain metropolitan 

areas with a greater potential for enhancing U.S. exports. Moreover, 

without such information, Commerce would be unable to identify the most 

successful Global Cities efforts and to draw lessons from them that could 

be applied more widely to enhance federal, state, and local collaboration 

to achieve NEI goals.

The third initiative to enhance federal-state collaboration identified by 

TPCC officials aimed to improve collaboration with national organizations 

that have shared interests in expanding U.S. exports. This initiative 

focused on strengthening Commerce’s relationship with the State 

International Development Organizations (SIDO), the only national 

organization devoted exclusively to supporting international trade 

development through state trade offices.45

 45SIDO members include state international trade agencies across the country. Through 

close partnership with the Council of State Governments, SIDO provides a forum where 

states regularly engage in trade promotion activities by bringing together state and local 

level international development professionals to share ideas and enhance skills. SIDO is 

based in Washington, D.C., but relies primarily on the active involvement of state trade 

directors across the country, including its board of directors, to ensure that all activities 

focus on the immediate needs of the states.

TPCC agencies also work with 

other national nonprofit organizations, including the National Governors 

Association and the U.S. Conference of Mayors. For example, the 

National Governors Association is developing a means to track and share 

Collaboration with SIDO 

and Other National 

Organizations Has Had 

Limited Results
Page 31 GAO-14-393 Export Promotion

information on trade missions involving state governors. However, 

promoting trade is not the primary purpose of these two entities.

SIDO’s mission is to provide a forum for collaboration and sharing best 

practices, advocating for states’ international trade and development 

issues, and supporting the goals of the NEI through coordination of 

federal and state resources. A SIDO official told us that while many states 

have good collaborative relationships with federal officials at the local 

level, there was less collaboration at the national level in Washington, 

D.C. Both Commerce and SIDO were hopeful that a formal agreement 

would encourage dialogue and improve collaboration. In September 

2011, Commerce and SIDO signed a memorandum of intent (MOI) that 

articulated their commitment to work together to develop strategies and 

implement activities in three areas.

• They agreed to enhance Commerce’s partnership with state trade 

offices to coordinate and cooperate in the delivery of critical customerfocused services necessary to assist U.S. companies to successfully 

export their products and services and enter new foreign markets.

• They agreed to identify opportunities and mechanisms for Commerce 

and the states, working through SIDO, to increase awareness among 

companies of available services, trade programs, and overseas 

events.

• They agreed to create a formal consultation process between 

Commerce and SIDO to facilitate communication and coordination, 

exchange ideas, and identify joint activities to be carried out pursuant 

to a future agreement.

The MOI represented a concerted effort on the part of Commerce and 

SIDO to improve collaboration consistent with two key collaboration 

practices. First, the MOI was a written agreement documenting how SIDO 

and Commerce believe collaboration should occur. Second, the MOI 

defines the three common outcomes listed above. Nonetheless, the MOI 

did not specify roles and responsibilities; provide a mechanism to monitor, 

evaluate, and report on results; address how to leverage state and federal 

resources; or identify activities to achieve the three outcomes. One 

Commerce official commented that there was no commitment embedded 

in the agreement, such as a list of specific actions and who would be 

responsible for carrying them out. Similarly, one SIDO member 

commented that, while the agreement had gotten the parties together, it 

was too general to help them move forward and accomplish much. In 

contrast, a draft memorandum of understanding (MOU) that had 

preceded the MOI, did call for specific actions, such as having Commerce 

and SIDO jointly organize a program of multistate trade missions to key 
Page 32 GAO-14-393 Export Promotion

markets worldwide and developing procedures to enable federal and 

state trade offices to share credit for successful export promotion efforts. 

According to SIDO members and Commerce officials, legal concerns 

about vetting such a specific agreement in the short time frames given 

prompted them to sign the MOI instead.

Ultimately, the MOI, which was to be renewable annually, expired in 

September 2012 with limited results, according to SIDO officials. SIDO 

and Commerce officials reported diverging views about progress on 

achieving the three common outcomes. Regarding the first activity—

coordinating and cooperating in the delivery of critical customer-focused 

services—SIDO officials noted a continued lack of joint planning. For 

example, several SIDO members had expressed frustration about being 

surprised by Commerce’s announcements of new nationwide initiatives, 

including those for Export Outreach Teams and the precursor of Global 

Cities, the Metropolitan Export Initiative. Regarding the second activity—

increasing awareness among companies of available services—SIDO 

officials stated that Commerce has not yet instituted a formal mechanism 

to notify state trade offices about upcoming events such as trade shows 

in time for state offices to assist or participate. Commerce officials, on the 

other hand, told us that it resolved this issue by sending SIDO a long list 

of TPCC upcoming activities twice a year, as well as regular postings on 

Commerce’s export.gov website. Commerce officials pointed out that 

states also need to share with Commerce their plans regarding such 

events, which they said does not always occur, particularly since the 

states started obtaining additional funds through the STEP program. For 

example, the governors of Kentucky and Wyoming held a trade show for 

their mining equipment companies geared toward sales to China at the 

same time as Commerce’s similar efforts. Regarding the third activity, 

formal consultation, Commerce and SIDO created a consultation process 

through which, at the onset, they met quarterly, according to Commerce 

officials. However, according to SIDO officials, the meetings neither 

generated any actions nor produced an agreement, as called for in the 

MOI. Moreover, a 2013 survey of SIDO members indicated that most 

believed that despite the NEI, federal-state collaboration in promotion 

exports had not improved in recent years.

According the Commerce and SIDO officials, several factors contributed 

to the limited collaboration stemming from the MOI. These officials agreed 

that collaboration was a joint responsibility and a SIDO official said that 

they had not met with Commerce since April 2013. A SIDO official also 

said that recent personnel changes on both sides made it more 

challenging to maintain regular consultations. Furthermore, SIDO officials 
Page 33 GAO-14-393 Export Promotion

said that they were now giving more priority to working with SBA and 

Congress to maintain funding for STEP. Nevertheless, the MOI’s 

consistency with key collaboration practices could have helped to 

enhance collaboration. Agreements to collaborate that define common 

outcomes but do not identify activities to achieve them or specify roles 

and responsibilities lack a roadmap to motivate parties to move forward. 

In addition, when such agreements lack a mechanism to monitor, 

evaluate, and report on results, they make it more difficult for the partners 

in collaboration to hold one another, and themselves, accountable for 

fulfilling their commitments.

SIDO officials called sharing credit in the tracking of export promotion 

successes their number one priority to enhance federal-state 

collaboration, which, according to those officials, is why they sought to 

address this issue in the MOI. Sharing information is consistent with the 

key collaboration practice of leveraging resources, including information 

technology, to support a common outcome. However, Commerce pointed 

out that it is required by law to restrict the extent to which it can share 

information (e.g., clients’ new export markets, export sales, customer 

satisfaction, services obtained), including information related to 

Commerce’s export successes.46

• First, they said they had no way of knowing whether their referrals of 

clients to Commerce for Gold Key services resulted in export sales, 

leading to underreporting of the state trade office’s results and limiting 

its ability to justify additional export promotion resources.

State trade office officials in two of the 

five states we visited also mentioned sharing client information as 

important to federal-state collaboration. For instance, an official from one 

state stated that sharing their client lists with Commerce and vice versa 

ensured that their customers obtained the best service to meet their 

needs. Officials from a third state cited three specific issues related to 

sharing client information:

• Second, they said that it is more difficult to advise companies 

effectively without knowing what information the companies may have 

already obtained from Commerce.

• Third, the officials said that they and Commerce had to distribute 

separate evaluation forms after jointly sponsored training events, 

 46As previously discussed, Commerce measures progress, in part, by tracking what it 

terms “export successes”—any trade promotion activity involving Commerce that 

successfully assists a U.S. company to export a product or service.

MOI Did Not Address Sharing 

Client Information
Page 34 GAO-14-393 Export Promotion

resulting in underreporting because participants generally did not want 

to fill out two forms.

Commerce USEAC officials in three of the states we visited said that they 

were prohibited by law from sharing information on client services with 

state trade offices. A USEAC official in one of the three states explained 

that Commerce must keep a confidential relationship with clients so that 

clients will report to them their export successes, an important 

performance measure. A USEAC official in one state noted, however, that 

sharing export success information with his state trade office counterpart 

made sense because they used similar metrics. The official commented 

that the ability to share export successes with the states would encourage 

leveraging of resources through joint efforts. In addition, this same 

USEAC official reiterated that underreporting occurs because the state 

trade office and Commerce must distribute separate evaluation forms to 

clients that attend their joint trade shows and trade missions and most 

clients will not take the time to complete both forms.

According to an official from Commerce’s Office of General Counsel, 

Commerce is legally barred by the federal Trade Secrets Act47 from 

sharing any information that would cause “substantial competitive harm” if 

released. The official commented that, as a general rule, companies are 

reluctant to release information to the government and that Commerce 

must obtain “affirmative permission” from each company in order to share 

nonpublic information with the states or other federal agencies. She 

stated the company must give permission in advance, in writing, through 

some formal process that would have to be captured in a database, with 

strict controls. She also stated that sharing client information with the 

state trade offices is particularly challenging because, unlike information 

Commerce shares with other federal agencies, information that 

Commerce discloses to a state government is automatically considered 

releasable to the public under the Freedom of Information Act.48

 4718 U.S.C. §1905.

However, 

she noted that Commerce officials can share any information already 

publicly available, or information that would clearly not cause substantial 

competitive harm. She stated that examples of such publicly available 

information would include a press release about a company attending a 

trade mission or information in a company’s annual report. Finally, the 

485 U.S.C. § 552.
Page 35 GAO-14-393 Export Promotion

official reiterated that Commerce can share any information with the 

states if a company gives formal written permission in advance.49

Commerce officials from ITA stated that they are now exploring ways for 

clients to voluntarily give permission for CS to release their information

but warned of several challenges.50

Commerce has circulated guidance in the form of a slide presentation 

about the need to protect confidential commercial information consistent 

with limitations on disclosure in the Trade Secrets Act and the Privacy 

Act,

They noted that CS currently lacks 

the technical capability to record a client’s advance permission to share 

their proprietary information, except in the case of fee-based services. In 

this regard, a Commerce official estimated that 15 percent of CS services 

are fee based. Finally, a Commerce official suggested that Commerce 

could aggregate the value of export successes by state. However, this 

would not indicate whether the state actually contributed to the export, 

thus preventing the state from documenting and sharing credit.

51

 49GAO recommended in January 2013 that federal agencies involved in export promotion 

identify ways to increase, where possible, sharing of client information. 

which officials said they sent to CS offices. According to an official 

from Commerce’s Office of General Counsel, Commerce had provided no 

official general guidance to its employees on what client information may 

be shared with other federal agencies, the states, or both, and in what 

situations. Instead, this official stated that Commerce lawyers assess 

information-sharing requests on a case-by-case basis and offer informal 

guidance. She noted that currently Commerce has no way to obtain 

formal permission from companies with regard to sharing information. 

However, without some formal, general guidance from Commerce on the 

types of information that can be shared consistent with legal restrictions, 

and without some effort by Commerce to obtain permission from its 

clients to share their information, federal and state export promotion 

providers have less opportunity to leverage resources, such as sharing 

GAO-13-217.

50In November 2012, the Commerce Inspector General (IG) found that restrictions on 

sharing Commerce’s client information hamper collaboration between USEACs and their 

partners. The IG recommended that Commerce explore the possibility of requiring CS 

clients to waive confidentiality, in whole or in part, as a condition for receiving services. 

See Department of Commerce, Office of Inspector General, International Trade 

Administration: U.S. Export Assistance Centers Could Improve Their Delivery of Client 

Services and Cost Recovery Efforts, OIG-13-101-1 (Washington, D.C.: Nov. 30, 2012).

515 U.S.C. § 552a.
Page 36 GAO-14-393 Export Promotion

clients and credit for export successes, and thus, less incentive to 

collaborate.

Federal and state governments share an interest in helping small 

businesses export in order to promote economic development and create 

good-paying jobs. Given the overlap of federal and state export promotion 

efforts and the current environment of constrained government resources, 

enhancing federal-state collaboration is important to help ensure that 

export promotion programs operate as efficiently and effectively as 

possible. It is also important for minimizing any potential barriers to small 

businesses seeking export promotion assistance. Nevertheless, 

collaboration is a two-way street, and the nature and extent of the federal 

and state relationship varies widely by state, depending on the unique 

factors in each state. The three recent TPCC initiatives to improve federal 

collaboration with states at the national and local levels recognize the 

varying nature of the collaborative relationship. Unfortunately, the federal 

initiatives have had limited success and only partially incorporated key 

collaboration practices. We found weaknesses in the implementation of 

Export Outreach Teams that limit their ability to achieve their objectives 

and enhance federal-state collaboration. Collaborative agreements with 

partners on the other two initiatives have expired with unknown or limited 

results. Nevertheless, these initiatives have demonstrated that fruitful 

opportunities exist to improve local networks of export promotion service 

providers, to expand activities to better include metropolitan area 

economic development agencies, and to work with national organizations 

representing state and local governments. Renewed effort by the TPCC 

agencies to implement these initiatives with greater attention to key 

collaboration practices can help improve the support available to small 

businesses hoping to export, as well as bolster, federal efforts to achieve 

national export goals.

To improve federal-state collaboration in providing export promotion 

services in accordance with the National Export Initiative, and the Export 

Enhancement Act of 1992, we recommend that the Secretary of 

Commerce, as Chair of the TPCC, take the following three actions:

• Improve implementation of the Export Outreach Teams to better 

achieve their intended outcomes. This could include taking steps, 

including better monitoring, to ensure that key local participants are 

invited, that meetings are held as expected, and that the Export 

Outreach Teams seek to both increase awareness of available export 

Conclusions

Recommendations for 

Executive Action
Page 37 GAO-14-393 Export Promotion

resources and enhance interagency and intergovernmental 

collaboration.

• Take steps consistent with key practices for collaboration to enhance 

TPCC agencies’ partnering on export promotion with nonfederal 

entities, such as SIDO and Global Cities. This could include 

reassessing and strengthening the TPCC’s intergovernmental 

partnerships by clarifying expected outcomes, defining roles and 

responsibilities, monitoring results, and planning resource needs.

• Take steps consistent with key practices to enhance, where possible, 

federal information sharing with state trade offices on Commerce’s 

export promotion activities. This could include more formal guidance 

to Commerce staff regarding the circumstances, in light of legal 

restrictions, in which information can be shared with state trade offices 

and other nonfederal entities, and exploring ways for clients to give 

permission to release information useful to such nonfederal entities.

We provided a draft of this report to Commerce and SBA for review and 

comment. In its written comments on the draft, which are reprinted in 

appendix III, Commerce concurred with our overall assessment that 

collaboration can be enhanced through strategic management. 

Commerce stated in its letter that our analysis was helpful in pointing out 

areas where TPCC agencies can enhance their relationship with state 

and local government partners. Commerce also noted that while our 

analysis of the status of federal cooperation with state trade promotion 

entities raises important issues, to make broader program decisions, 

Commerce would need to obtain input from a wider variety of state trade 

promotion entities beyond the five state programs that were the focus of 

our fieldwork. Commerce stated its intention to obtain comprehensive 

data on the overall federal relationship with state trade promotion entities 

and that once it obtained that additional data it would work to identify and 

implement strategies to enhance TPCC agencies’ collaboration with state

entities on trade promotion. Commerce also described steps that are 

ongoing or planned to address each of our three recommendations. 

• Consistent with our recommendation on Export Outreach Teams, 

Commerce noted that it will help SBA implement its reform plan to 

improve the Export Outreach Teams, including defining representative 

entities at the local level that should be included in the teams. 

• Commerce also noted that it is working with the Brookings Institution 

on raising awareness of best practices under the Global Cities 

Exchange program and working with Brookings and participating cities 

to assess the program’s impact. Commerce stated its intention to 

Agency Comments
Page 38 GAO-14-393 Export Promotion

monitor the impacts of Global Cities through data collected by the 

Census Bureau on the number of exporters in metropolitan areas. 

• Finally, Commerce noted that it has begun transmitting to SIDO 

information on federal activities, such as trade missions, earlier in the 

planning cycle; is working with SIDO to further analyze what makes 

for good federal-state cooperation; and plans to hold quarterly calls 

with state trade promotion entities on mutually agreed-on topics.

Commerce also stated in its letter that our analysis of the Export 

Outreach Teams paralleled that of SBA in its review of the new program; 

and that SBA is taking a number of steps that align with our 

recommendation, such as defining representative entities at the local 

level that should be included in the Export Outreach Teams.

In addition, on May 1, 2014, the SBA Deputy Associate Administrator for 

International Trade provided us with comments in an e-mail on the draft, 

stating that our analysis and conclusions regarding its implementation of 

Export Outreach Teams were largely accurate and that SBA will allow the 

implementation process to unfold over the next year, after which it will 

review and assess any need for improvements, in line with our 

recommendations. SBA also clarified that the Export Outreach Teams 

were a TPCC initiative co-led by Commerce and SBA, as reflected in the 

mandate in the original TPCC Communiqué; we incorporated this change. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 14 days from the 

report date. At that time, we will send copies to the Secretary of 

Commerce, the SBA Administrator, and other interested parties or 

congressional committees. In addition, the report will be available at no 

charge on the GAO Website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-8612 or at gianopoulosk@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 
Page 39 GAO-14-393 Export Promotion

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix IV.

Sincerely yours,

Kimberly Gianopoulos

Acting Director, International Affairs and Trade
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-14-393 Export Promotion

In this report, we examine (1) the main characteristics of federal and state 

export promotion efforts, including their collaboration, and (2) the extent 

to which the Trade Promotion Coordinating Committee (TPCC) has 

advanced collaboration between state and federal efforts to promote U.S. 

exports.

While some of the 20 TPCC member agencies directly assist small 

businesses to export overseas, this review focuses solely on the 

Department of Commerce (Commerce) and the Small Business 

Administration (SBA). This is because the other TPCC agencies generally 

provide export promotion services comparable to those that state trade 

offices provide.1

To determine the main characteristics of federal and state export 

promotion efforts, we compared their sizes, services, types of clients, and 

performance measures using information collected from interviews and 

site visits to offices of Commerce’s Commercial Service (CS) and state 

trade offices in five states (Florida, Minnesota, Oregon, Pennsylvania, 

We conducted our work in Washington, D.C., and 

through fieldwork in five states: Florida, Minnesota, Oregon, 

Pennsylvania, and Virginia. We chose these states based upon the 

following criteria: presence of a District International Trade officer, SBA 

District Office, and Commerce U.S. Export Assistance Center in the 

metropolitan areas we planned to visit; initiation of Export Outreach 

Teams; state trade office presence overseas; participation in Global Cities 

Exchange; extent of collaboration with federal export promotion providers 

according to Commerce officials in Washington, D.C.; and state trade 

office staff size (mix of large and small). We chose these locations to 

better understand and test federal initiatives to advance collaboration with 

state trade offices at the local level; these five locations allowed us to 

assess federal implementation efforts overall but are not representative of 

the situations in each of the individual 50 states.

 1

The Department of State and U.S. Trade and Development Agency support some export 

promotion but focus their efforts internationally. The U.S. Department of Agriculture 

provides export promotion services through industry organizations and other mechanisms. 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-14-393 Export Promotion

and Virginia).2 State trade office Directors and their staff provided detailed 

information regarding their office locations, staffing numbers, services 

provided, clients served, annual budgets, and the metrics used to 

measure their programs for fiscal years 2012 and 2013. To assess the 

reliability of these data, we created a standard set of questions that was 

sent to each of the five states. We cross-checked these data with similar 

fields in the SIDO 2012 and 2013 survey data. We also collected 

information on SBA services, clients, and resources from documents and 

interviews with SBA officials. We analyzed data collected by the State 

International Development Organizations (SIDO) in its annual member 

surveys for 2012 and 2013. To assess the reliability of the survey data 

from SIDO, we interviewed the SIDO representative responsible for 

developing and implementing the survey, performed a formal review of 

the survey questionnaire for methodological quality, and performed data 

testing. All variables from the survey in this report were determined to be 

sufficiently reliable for the purposes of this engagement. To calculate 

export successes and partnerships with state trade offices associated 

with export successes, we analyzed data from the Commerce’s Client 

Tracking System (CTS).3

 2

In this report, we defined “export promotion activities” as previously defined in a recent 

GAO report on export promotion. See 

CTS, an operational database used by field 

specialists and local office management, tracks fee-based and non-feebased activities. CTS is the principal database used for tracking “export 

successes”—the primary performance measure for CS. We conducted 

analysis of CTS data for fiscal year 2012 that identified export successes 

by state and types of partnerships. On the basis of interviews with 

knowledgeable agency officials and our assessment of the data for 

missing data, outliers, and obvious errors, we concluded that all data 

elements we assessed in the export successes data provided to us by 

Commerce were sufficiently reliable for the purpose of this report. To 

determine the extent of federal and state collaboration on export 

GAO-13-217, Export Promotion: Small Business 

Administration Needs to Improve Collaboration to Implement Its Expanded Role

(Washington, D.C.: Jan. 30, 2013). Export promotion activities are defined as programs 

and services conducted by federal agencies that involve direct contact with U.S. exporters 

and have export promotion as their stated goal. Such activities include providing small 

businesses with export counseling, training, and financial assistance; they do not include 

activities such as advocacy, commercial diplomacy, and policy development and 

negotiations.

3

CTS does not require that fields that indicate partnerships be completed; consequently, 

the data analyzed do not provide a complete picture of the extent to which state trade 

offices and CS collaborate to achieve export successes. 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-14-393 Export Promotion

promotion, we met with cognizant officials from CS and state trade offices 

in the five states we visited. We compiled information from state trade 

office websites on their international presence abroad. If information was 

not readily available, we contacted staff in the state trade offices by e-mail 

or telephone for information about their overseas presence. We crosschecked these data with similar fields in the SIDO survey data. U.S. trade 

data prepared by the U.S. Bureau of Economic Analysis are used in the 

report to illustrate the progress toward the National Export Initiative (NEI) 

goal of doubling 2009 export levels by 2015.

To address the extent to which the TPCC has supported collaboration 

between federal and state efforts to promote U.S. exports, we reviewed 

the Export Enhancement Act of 1992, which directed the President to 

establish the TPCC; Executive Order 12870 (Sept. 30, 1993) that 

established the TPCC in accordance with the 1992 act; and Executive 

Order 13534 (Mar. 11, 2010) announcing the NEI, as well as the 2011 

and 2012 editions of the TPCC’s annual National Export Strategy reports 

to Congress. We also asked the TPCC to identify their main efforts to 

collaborate with state and local agencies that have a role in export 

promotion. They identified three initiatives: Export Outreach Teams, the 

Global Cities Exchange (initially referred to as the Metropolitan Export 

Initiative), and the memorandum of understanding (MOU) between 

Commerce and SIDO. To evaluate the three initiatives, we interviewed 

staff of the TPCC Secretariat, which is housed in Commerce, as well as 

cognizant Commerce and SBA officials at headquarters. We analyzed the 

documents that provide a framework and guidance for the administration 

of Export Outreach Teams, as well as documents that describe the Global 

Cities Exchange and Commerce’s relationship with the Brookings 

Institution and SIDO. These documents include a TPCC interagency 

communiqué formalizing the Export Outreach Teams and the subsequent 

program guidance issued by SBA, data collected about the first Export 

Outreach Team meetings, formal agreements between Commerce and 

the Brookings Institution and between Commerce and SIDO, and 

documents from the Brookings Institution that describe the goals of the 

Global Cities Exchange. We also interviewed representatives from the 

Brookings Institution and SIDO to obtain their perspectives and discuss 

relevant ongoing changes to their programs and other efforts.4

 4

It should be noted that, although states are SIDO members, SIDO itself is a professional 

association without the ability to take binding actions on behalf of its members, and so its 

positions and actions do not necessarily reflect the views of all its members.

In 
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-14-393 Export Promotion

reviewing the Commerce-SIDO MOU, we reviewed the Trade Secrets Act 

and pertinent legal opinions regarding the act’s applicability, and we 

consulted with a representative of Commerce’s Office of General Counsel 

regarding that office’s views on how the act affects Commerce’s ability to 

share information with other federal, state, and local agencies. Finally, we 

met with a number of national organizations that represent the interests of 

local government entities to obtain their perspectives and ascertain their 

roles in promoting U.S. exports. The organizations we contacted include 

the National Governors Association, United States Conference of Mayors, 

National Association of Counties, and the National League of Cities.

We also reviewed GAO’s guidance regarding good practices for 

coordinating and managing multiagency initiatives as described in other 

GAO reports, including those discussing implementation of the 

Government Performance and Results Act (GPRA) of 1993 and the 

GPRA Modernization Act of 2010.5

We conducted this performance audit from February 2013 to May 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

In states we visited, we interviewed 

staff at state trade offices, federal officials from Commerce and the SBA 

District Offices. On the basis of recommendations from federal or state 

officials in those states, we met with other local entities, including trade 

associations, economic development organizations, Small Business 

Development Centers (SBDCs), representatives from District Export 

Councils, local chambers of commerce, and the mayor’s offices in Miami, 

Florida; Minneapolis, Minnesota; and Portland, Oregon, to obtain 

information about local approaches to interagency collaboration and 

about implementation of the three TPCC initiatives. We then discussed 

what we found on our site visits with officials from TPCC, Commerce, and 

SBA in headquarters to obtain their input.

 5

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 

We identified these practices through interviews with experts on collaboration and a 

review of findings from a number of our previous reports on collaboration in the federal 

government; and Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012). To develop 

these considerations, we reviewed relevant literature, including our prior work, and 

interviewed experts in the area of collaboration.
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-14-393 Export Promotion

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Commerce and State Trade Office 

Representation Overseas

Page 45 GAO-14-393 Export Promotion

Figure 7 identifies countries in which the Department of Commerce 

(Commerce) and state trade offices have representation overseas. 

Commerce representation consists of U.S. Commercial Service staff 

located in offices overseas. State trade office representation includes 

state employees located in offices in-country and contractors hired as 

service providers who provide services to a country from offices located 

in-country, or on a regional basis from offices not located in-country, or 

both.

Appendix II: Commerce and State Trade 

Office Representation Overseas
Appendix II: Commerce and State Trade Office 

Representation Overseas

Page 46 GAO-14-393 Export Promotion

Figure 7: Commerce and State Trade Office Representation Overseas
Appendix II: Commerce and State Trade Office 

Representation Overseas

Page 47 GAO-14-393 Export Promotion

Figure 7: Commerce and State Trade Office Representation Overseas (continued)
Appendix III: Comments from the Department 

of Commerce

Page 48 GAO-14-393 Export Promotion

Appendix III: Comments from the 

Department of Commerce
Appendix III: Comments from the Department 

of Commerce

Page 49 GAO-14-393 Export Promotion
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 50 GAO-14-393 Export Promotion

Kimberly Gianopoulos, (202) 512-8612, or gianopoulosk@gao.gov.

In addition to the contact named above, Adam Cowles (Assistant 

Director), Qahira El’Amin, Nina Pfeiffer, and Cristina Ruggiero made key 

contributions to this report. Gezahegne Bekele, David Dayton, David 

Dornisch, Etana Finkler, and Ernie Jackson provided technical 

assistance.

Appendix IV: GAO Contact and Staff 

Acknowledgments

Contact

Staff 

Acknowledgments

(320964)
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